In April 2008, CRA released a Consultation on proposed policy regarding fundraising by Registered Charities (RC4456-e) (“Fundraising Consultation”). This document is a relatively short six page overview, and CRA has recently provided charities with a more detailed document entitled “Background information for proposed policy on fundraising by Registered Charities” which is 29 pages (“Background Document”). The background document provides greater detail, further definitions of terminology and CRA’s positions on various points. In this article I will discuss the content of the Fundraising Consultation and Background Document, discuss and analyze the criticisms from others of these documents, and provide my own comments.
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Mark Blumberg is a partner at the law firm of Blumberg Segal LLP in Toronto and works almost exclusively in the areas of non-profit and charity law.